Mandatory Disclosures as per Clause 38 of IFSCA Circular - Regulatory Framework for Global Access in the IFSC dated August 12, 2025

Effective date - October 30, 2025

INDmoney Global (IFSC) Private Limited (“INDmoney Global”) is mandated to disclose to investors risk factors relating to investments in Global Market, roles and responsibilities of entities involved in providing global access, Details of custody arrangements, Account structure, Trading related information including methodology used for calculating profit and loss of clients and other details as laid down under Clauses 38 and related provisions of IFSCA circular — Regulatory Framework for Global Access in the IFSC and the IFSCA (Capital Market Intermediaries) Regulations, 2025.

  1. Risk Factors Relating to Investment in Global Markets
    1. Market Risk

      Investments are executed in markets outside the IFSC, which operate under different laws, trading hours, holiday calendars, disclosure norms, and investor-protection standards. Prices may fluctuate due to local or global market conditions.

    2. Currency Risk

      Foreign investments are subject to exchange-rate fluctuations. Adverse currency movements may reduce or negate investment gains when converted to the investor’s base currency.

    3. Custody Risk

      Securities or funds may be held with foreign brokers, custodians, or other intermediaries. Their insolvency, operational failure, or negligence could lead to partial or total loss of investments.

    4. Liquidity and Settlement Risk

      Settlement cycles and market liquidity may differ across jurisdictions. Variations in market practices or operational processes could cause delays in execution or settlement of trades.

    5. Technology and Time-Zone Risk

      Orders placed through electronic systems across different time zones are exposed to latency, outages, or price gaps due to time-zone differences and system dependencies.

    6. Product and Suitability Risk

      Products available in foreign markets may be complex and involve higher risk than domestic instruments. Investors must ensure that such products suit their financial condition, objectives, and risk tolerance.

    7. Regulatory and Legal Risk

      Foreign investments are governed by the laws and regulations of the relevant jurisdiction. Investor-protection standards, disclosure requirements, dispute-resolution mechanisms, and supervisory frameworks may vary from those in India or the IFSC. Investors should remain informed of applicable regulatory changes.

    8. Taxation Risk

      Investments may attract taxes, withholding, or reporting obligations in both India and the foreign jurisdiction. Tax treatment is subject to change without notice. Investors are responsible for ensuring compliance with all applicable tax laws and maintaining adequate records.

    9. Remittance and Regulatory Compliance Risk

      All fund transfers must comply with the applicable laws of India, the IFSC, and the foreign jurisdiction, including the Reserve Bank of India’s Liberalised Remittance Scheme (LRS). Any breach of such rules may attract regulatory or penal action.

  2. Roles and responsibilities of entities involved in providing global access

    INDmoney Global (IFSC) Private Limited(“Company”) is a IFSCA registered Broker-Dealer. The Company has direct arrangements with US based clearing brokers: Alpaca Securities LLC and DriveWealth LLC is a US based clearing broker registered with the U.S. Securities and Exchange Commission (SEC) and is a member of FINRA. Alpaca Securities LLC and DriveWealth LLC are members of multiple US stock exchanges.

  3. Details of custody arrangements

    a. Alpaca - custody arrangement

    All trades placed by investors are executed through Alpaca Securities LLC. Alpaca Securities LLC is a self clearing member of the DTCC and NSCC, which acts as a centralized clearing and settlement company for different securities and asset classes. The DTCC also serves as the central custodian at the depository level.

    b. Drivewealth - custody arrangement

    All trades placed by investors are executed through Drivewealth LLC. Drivewealth LLC is a self clearing member of the DTCC and NSCC, which acts as a centralized clearing and settlement company for different securities and asset classes. The DTCC also serves as the central custodian at the depository level.

  4. Account structure

    Investors are required to register on the INDmoney platform and complete all KYC procedures mandated by the Regulatory Framework for Global Access in the IFSC and the IFSCA (Capital Market Intermediaries) Regulations, 2025 and other regulatory guidelines. Upon successful AML-KYC verification, INDmoney Global will open a trading account for the investor. US stocks trade execution/ settlement necessitates use of a U.S. clearing broker, INDmoney may facilitate the opening of a clearing account with US broker (i.e. Alpaca/ Drivewealth); the opening and continued operation of the clearing account shall be conditional upon the investor’s fulfillment of specific foreign broker’s KYC, onboarding and any other applicable requirements.

  5. Trading related information including methodology used for calculating profit and loss of clients

    The trading activities related to US stocks on INDmoney platform and fulfillment and clearing of the trades are done the US based stock-brokers directly for the clients

    All computation of holdings, average prices, quantity, and profit and loss are done basis the FIFO method as a general practice and shown to the investor on the INDmoney platform. All reports of transactions, holdings and tax p&l are available on INDmoney platform for the investor to download as per India tax reporting formats

    Illustration of FIFO methodology used while buying & selling of US shares

    FIFO stands for First-In, First-Out. It is a method used to track which shares are sold when you make a sale, especially when you’ve bought the same stock multiple times at different prices. Under FIFO, the oldest shares (first bought) are assumed to be sold first. This is the standard method used in India (as per Income Tax rules) and globally.

    Example: Let’s say you buy shares of Company XYZ multiple times:

    1. BUY - Jan 1 - 10 Shares - $100 per share
    2. BUY - Feb 1 - 10 Shares - $120 per share

    And then SELL 15 shares on 1 Mar at $150 per share. As per FIFO:

    1. First, 10 shares from Jan 1 ($100 each) are sold
    2. Then, 5 shares from Feb 1 ($120 each)

    Realized Gain:

    1. 10 × ($150 − $100) = $500
    2. 5 × ($150 − $120) = $150
    3. Total Realized Gain = $650

    Note - When shares are sold, the invested value is not reduced by the sale proceeds. Instead, the invested value is adjusted based on the original cost of the shares sold, which is calculated using the FIFO (First In, First Out) method.

  6. Applicable fee structure

    Investing in US stocks through INDmoney is highly affordable and competitive in the industry, with minimal charges:

    1. Opening a US stocks account via INDmoney is Free
    2. Zero AMC (Annual Maintenance Charges)

    Read more about INDmoney charges

  7. Applicable investor protection scheme or insurance coverage
    Foreign BrokerIs Foreign Broker member of SIPC?Applicable investor protection scheme or insurance coverageAdditional Link
    Alpaca Securities LLCYesSIPC currently protects the securities and cash in your brokerage account up to $500,000 of which $250,000 may be in cash.https://alpaca.markets/support/is-my-account-insured-what-is-sipc
    Drivewealth LLCYesSIPC currently protects the securities and cash in your brokerage account up to $500,000 of which $250,000 may be in cash.https://legal.drivewealth.com/customer-account-agreement

    Alpaca Securities LLC and Drivewealth LLC are members of the Securities Investor Protection Corporation (SIPC). SIPC currently protects the securities and cash in your brokerage account up to $500,000 of which $250,000 may be in cash.

  8. Applicable tax structure

    For Indian residents:

    1. Short‑Term Capital Gains (STCG): If US stocks are sold within 24 months, gains are taxed as per your income‑tax slab.
    2. Long‑Term Capital Gains (LTCG): If sold after 24 months, gains are taxed at 12.5% without indexation.

    Read all about Tax Implications on US Stocks

  9. Timely communication of corporate announcements

    FCorporate announcements such as mergers, dividends and bonus/splits are communicated to investors on a best effort basis on INDmoney platform. Dividends, Bonus and other corporate actions are performed by the clearing broker in the US and will reflect on INDmoney platform. Dividends paid out to investors are credited directly to the investors wallet post deduction of applicable withholding taxes.

  10. Entry fee, exit fee, fund withdrawal charges, account transfer charges, account closure charges or any other charges shall be disclosed at the time of onboarding client and an undertaking that no other charge other than what is disclosed will be collected from the client.

    There is no Entry fee, exit fee, fund withdrawal charges, account transfer charges or account closure charges.

    Read more about INDmoney charges

  11. Regulatory requirements with respect to trading in such foreign Jurisdiction

    The Resident Indian investor’s participation in global markets through the authorised Global Access Provider (GAP) is subject to compliance with all applicable laws and regulations, including but not limited to the Foreign Exchange Management Act, 1999 (FEMA) and the Liberalised Remittance Scheme (LRS) of the Reserve Bank of India (RBI).

    Remittance towards investing in US Stocks via the Liberalized Remittance Scheme (LRS) is regulated by the Reserve Bank of India (RBI). As a resident Indian, you are allowed to remit up to $250,000 a year. Read more about Liberalised Remittance Scheme

    Investor understands the trade Access Restriction with regards to: a.Crypto-assets and instruments having underlying assets as crypto or any other instruments b. Index derivatives, single stock derivatives, bond derivatives or USD-INR/INR-USD derivatives that are available on Recognised Stock Exchanges in the IFSC.

    Investors can reach out to INDmoney Global for any kind of complaints/ grievances as per the process laid down in the Policy on Complaint Handling and Grievance Redressal - Global Access . Investors are requested to acknowledge that all disputes related to Global Access will not have access to the Rights of investors or investor protection; Dispute resolution mechanism; and Investor grievance redressal mechanism of the recognised stock exchanges in the IFSC.

  12. By continuing, I confirm that I have read, understood, and accepted these risks and disclosures.